Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The AT dismissed the appeals; the provisional attachment orders under PMLA s.5(1) are upheld. The Tribunal held provisos to s.5(1) must be read with the main provision and permits attachment of property as "value thereof" even when the second proviso is invoked. Because money laundering requires proceeds of crime, a property acquired pre-offence may nonetheless remain attached where prima facie material suggests layering by a relative; however, final determination awaits the complete predicate investigation. The Directorate's restrained approach in securing a single property was endorsed. The appellants failed to produce corroborative evidence to rebut the attachments; consequently the appeals are dismissed and the properties remain secured pending further proceedings.
The AT dismissed the appeals; the provisional attachment orders under PMLA s.5(1) are upheld. The Tribunal held provisos to s.5(1) must be read with the main provision and permits attachment of property as "value thereof" even when the second proviso is invoked. Because money laundering requires proceeds of crime, a property acquired pre-offence may nonetheless remain attached where prima facie material suggests layering by a relative; however, final determination awaits the complete predicate investigation. The Directorate's restrained approach in securing a single property was endorsed. The appellants failed to produce corroborative evidence to rebut the attachments; consequently the appeals are dismissed and the properties remain secured pending further proceedings.
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